Meridian Economics has submitted its formal comment on Eskom’s coal flexibilisation study, undertaken as part of Eskom’s obligations arising from the Minimum Emission Standards (MES) exemption decision. While Eskom’s technical report provides a useful baseline by assessing minimum stable levels across selected coal stations, its narrow emphasis on this single flexibilisation lever overlooks the broader suite of options available to enhance the flexibility of the coal fleet. In particular, our modelling demonstrates that the seasonal shutdown of coal units offers substantially greater system-wide cost savings than incremental improvements to minimum stable levels, while also delivering major environmental benefits. Our comment calls on Eskom to expand its flexibilisation analysis to include seasonal shutdowns explicitly, and to undertake a thorough assessment of feasibility, operational risks, cost implications, and the contribution of this option to overall system flexibility and stability.
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